Failure Mode and Effects Analysis (FMEA): Risk Table#

ISO 14971:2019 Section

Document Section

5.2

(all; entries about reasonably foreseeable misuse)

5.4

3

5.5

3, 4

6

3

7.1

4

7.2

4

7.3

4

7.5

4

IEC 62366-1:2015 Section

Title

Document Section

4.1.2

Risk Control as it relates to User Interface design

4

5.3

Identify known or foreseeable Hazards and Hazardous Situations

1,3

This is a Failure Mode and Effects Analysis (FMEA) of the device. It is separated into multiple sections:

  • Failure Modes lists everything which can go wrong

  • Hazards and Analysis lists everything (harms) which can subsequently happen, including an analysis of probability and severity

  • The list of Risk Control Measures which contains all control measures which were implemented for risk reduction, either reducing probability or severity, or both.

1. Preliminary Hazards Analysis (PHA)#

Table 1 Preliminary Hazards Analysis#

ID

Source

Description

Hazard ID(s)

1

Intended Use

Avoidance organ under-contoured

1

2

Intended Use

Avoidance organ over-contouring

2

3

Intended Use

Target under-contouring

3

4

Intended Use

Target over-contouring

4

5

Technical considerations

No contour produced

5

6

Technical considerations

Delay in contour production

6

7

Usability

Contour misidentified

7

8

IT Security

Leakage of Patient Information

8

2. Failure Modes#

Table 2 Failure Modes#

ID

Failure Mode

Hazard ID(s)

1

Incorrect contour

1, 2, 3, 4, 5

2

Security breach

8

3

Cloud server computation bottlenecks

6

3. Hazards and Analysis#

Table 3 Hazards, Hazardous Situations, and Harm#

ID

Hazard

p1

Hazardous Situation

p2

Harm

1

Avoidance organ under-contoured

10^-5

Radiotherapy treatment plan created and delivered to the patient which irradiates the under-contoured region

10^-3

Death or serious disablement

2

Avoidance organ over-contouring

10^-5

Radiotherapy treatment plan created and delivered to the patient which compromises too much on target

10^-2

Reduced treatment outcomes

3

Target under-contouring

10^-3

Radiotherapy treatment plan created and delivered to the patient which compromises too much on target

10^-2

Major treatment protocol deviation, significantly reduced treatment outcomes

4

Target over-contouring

10^-3

Radiotherapy treatment plan created and delivered to the patient where a compromise was needed between organ at risk and the target due to its over contouring

10^-2

Increased treatment side-effects

5

No contour produced

10^-5

Radiotherapy treatment plan created and delivered to the patient irradiating the organ

10^-2

Death or serious disablement

6

Delay in contour production

10^-2

Contour needs to be undergone manually following current standard practice

10^-2

Delay in treatment

7

Contour misidentified

10^-5

Radiotherapy treatment plan created and delivered to the patient irradiating the organ

10^-2

Death or serious disablement

8

Leakage of Patient Information

10^-6

Cloud server security breach

10^-1

Patient identifying data leak

Table 4 Analysis without risk controls#

ID

p1*p2

P

S

Acceptable without risk controls?

1

10^-8

P2

S5

No

2

10^-7

P3

S3

Yes

3

10^-5

P4

S4

No

4

10^-5

P4

S2

Yes

5

10^-7

P3

S5

No

6

10^-4

P4

S1

Yes

7

10^-7

P3

S5

No

8

10^-7

P3

S3

Yes

Table 5 Analysis with external risk controls#

ID

External Risk Control ID(s)

P

S

Acceptable with external risk controls?

1

1, 2

P1

S5

Yes

2

1, 2

P1

S3

Yes

3

1, 2

P2

S4

Yes

4

1, 2

P2

S2

Yes

5

1, 2

P1

S5

Yes

6

P4

S1

Yes

7

1, 2

P1

S5

Yes

8

P3

S3

Yes

Table 6 Analysis with external and internal risk controls#

ID

Internal Risk Control ID(s)

P

S

Acceptable with all risk controls?

1

3

P1

S5

Yes

2

3

P1

S3

Yes

3

3

P1

S4

Yes

4

3

P1

S2

Yes

5

3

P1

S5

Yes

6

P4

S1

Yes

7

3

P1

S5

Yes

8

4

P3

S2

Yes

4. Risk Control Measures#

Table 7 Risk Control Measures#

ID

Description

Type

Probability Reduction

Severity Reduction

1

The contour data is provided to an independent software treatment planning system where that independent software is utilised for refinement and approval by a relevant qualified health practitioner.

External measure – Health care procedure

10^2

0

2

The subsequent refined contours are then reviewed by at least one other independent relevant qualified health practitioner. Generally however the whole plan, including the contours goes through multiple independent reviewers before being utilised for treatment.

External measure – Health care procedure

10^2

0

3

After the refinements have been completed they are sent back to the software. The level of refinements are then compared to the original model results and feedback on this compared to the standard amount of refinement generally undergone for that contour type is then provided via notification to an independent relevant qualified health practitioner.

Internal measure – Information for safety

10^2

0

4

All identifying patient information is deidentified prior to submitting the data to the cloud server

Internal measure – Protective measure

0

1